Europaudvalget 2022-23 (2. samling)
KOM (2022) 0559 Bilag 2
Offentligt
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Brussels Monday 28 November 2022
Open letter sent by e-mail to:
Member states across the EU
CC: to Commissioner for Environment, Oceans and Fisheries, Virginijus
Sinkevičius
Director General for Maritime Affairs and Fisheries, Charlina Vitcheva
BALTFISH, and The Scheveningen Group
Dear Ministers
Please Keep Eel Fisheries Open: save the European Eel and small-scale
fishing communities
We write to urge you not to adopt a new regulation, due to be voted on in the
December AgriFish Council, to implement a 6-month closure on all European Eel
fishing in marine and adjacent brackish waters, as set out in the Commission’s
Proposal for fishing opportunities for 2023
1
.
This proposal and the current 3-month closure period will shut down the
marine eel fisheries for good. It will not save the eel
2
, and it will
undermine eel management, which is placed
rightfully
within the
framework of the European Eel Regulation from 2009 (Council Regulation
(EC) No 1100/2007). Furthermore, this proposal ignores many of the
recommendations made by ICES in their response to the EU request for
technical evaluation of the Eel Management Plans progress reports.
3
We as representatives of small-scale low impact fishers from across the EU call
for:
A more comprehensive approach, using both fisheries and non-fisheries
related measures, to ensuring the recovery of the eel
1
2
Press release from EU Commission, 22
nd
of October 2022,
link here
.
Although reduction in marine catches is expected to have a positive impact on the potential spawning stock in the long term, none of the
options suggested above would be sufficient to achieve the 40% escapement biomass target of the EC Eel Regulation for any sea basin by
2020”. ICES: EU request to provide advice on fisheries-related
anthropogenic impacts on eels in EU marine waters, 2017.
3
ICES (2022): EU request for technical evaluation of the Eel Management Plan progress reports. ICES Advice: Special Requests. Report.
https://doi.org/10.17895/ices.advice.19902958.v2
LIFE Brussels Office, Rue Cuypers, 3, 1040 Brussels, Belgium.
Tel: (+ 32) 486368855 ; E mail: [email protected]
kom (2022) 0559 - Bilag 2: Henvendelse af 8/12-22 fra Foreningen for Skånsomt Kystfiskeri vedr. ålefiskeriet og fiskekvoter for 2023
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A renewed focus and more effort on implementing the Eel Regulation,
adopted in 2007.
We urge Member States to agree to an alternative to the current 3-month closure.
We request that member states implement measures other than a fishery
closure. As specified in the text of the Fishing Opportunities for
2023
proposal, there should be an alternative to the closure period where
Member States have the opportunity to implement their own measures to
allow eel fishing to continue while still contributing to recovery of the eel.
We also call for improved data collection on the escapement of silver eels and
on glass eel recruitment. Small-scale fishermen across the EU have observed large
increases in the abundance of eel at all life stages.
-----------------------------------------------------------
BACKGROUND: In 2007 EU Member States agreed to establish a framework for
the protection and sustainable use of the stock of European eel. EU member states
agreed that the target should be achieved in “the long term”
(Council Regulation
(EC) 1100/2007).
According to the Evaluation of the Eel Regulation from 2020, there have been
notable successes in terms of reducing fishing mortality across the EU, but there
is still a need for a considerable improvement, especially when addressing non-
fisheries related anthropogenic mortality
4
.
Measures stipulated in the national eel management plans have been adopted
since 2009, however, implementation can and should be improved. Fishers
have played their part. Furthermore, the decline in glass eel recruitment has been
halted. The generation time of eel is around 13 years, and measures have been
in place for 13 years.
It was never the goal
nor possible
to rebuild the eel stock in such a short
timeframe. Eel recovery will take a long time. Today we are in a better situation
than when the eel regulation was adopted. Things are going in the right direction.
Despite this, you - EU Ministers and the European Commission (EC)
have started
to take measures outside of the agreed Eel Regulation.
Since 2018 the AgriFish Council of Ministers and the Commission have moved
decisions on the management of the eel to the yearly TAC negotiations in
December.
We see this as a very dangerous move, which we believe will jeopardize the
implementation of the Eel Regulation, and thereby the possibility of the Union, to
rebuild the eel stock and preserve the associated fisheries. The result will be
complete failure in achieving the key objectives of the Eel Regulation.
4
European Commission, Directorate-General for Maritime Affairs and Fisheries, MacNab, S., Luchetta, G., Nimmo, F., et al.,
Evaluation of
the Eel Regulation : final report,
Publications Office, 2020,
https://data.europa.eu/doi/10.2771/679816
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Those engaged in the fisheries have done much. Closing fisheries will be
counterproductive and, according to ICES, will be insufficient to ensure the targets
are reached.
Fishermen across the EU have engaged in the rebuilding of eel stocks for the last
13 years. They have reduced their fishing effort in line with the agreed EU Eel
Regulation, in the belief that Member States and the EC would also implement
other, non-fisheries measures, as well as establishing a fit for purpose data
collection system.
Due to a failure by Member States and the European Commission to do so,
fishermen will again pay the price. We
as fishers
can, and will, contribute
to eel conservation, employment and food security. If we are allowed to.
We urge you to not to make small scale fishermen pay the highest price. Please
don’t close our fisheries: give the Eel Regulation time to work, implement the
other needed measures in the member states, and implement an improved data
collection on glass eel recruitment and silver eel escapement.
With kind regards,
Brian O’Riordan
Executive Secretary, LIFE